BEFORE THE HON’BLE DISTRICT MUNSIFF COURT AT
SHOLINGANALLUR
I.A No. of 2025
in
O.S. No.416 of 2024
K. RANI,
W/o D. Kumar,
Rep. by Power Agent Mr. Manish Kumar,
E-20/56, Siddarth Nagar, New Delhi – 110014.
…Petitioner/Plaintiff
-Versus-
1. V.RANI
W/o Valayapathy
Plot No.648,
4TH main road, Ram Nagar South,
Madipakkam, Chennai
Also having address at
No.11, Malayappan Street,
Mandavelipakkam,
Chennai- 600 028
2. M.VEERASAMY
Plot No.648,
4TH main road,
Ram Nagar South,
Madipakkam, Chennai.
3. MR. VELAYUTHAM
Plot No.648,
4TH main road,
Ram Nagar South,
Madipakkam, Chennai.
… Respondents/ Defendants
AFFIDAVIT OF PETITIONER/PLAINTIFF
I, Mr. Manish Kumar, S/o D. Kumar, aged about 29 years, residing at E-
20/56, Siddarth Nagar, New Delhi – 110014, Power Agent of the Plaintiff in
O.S. No.416 of 2024 on the file of this Hon’ble Court, do hereby solemnly
affirm and sincerely state as follows:
1. I am the Power Agent of the Plaintiff and am well acquainted with the
facts of the case. I am authorised to file this affidavit on behalf of the
Plaintiff.
2. The above suit is filed for a decree of mandatory and permanent
injunction against the Defendants, restraining them from trespassing
and interfering with the peaceful possession of the Plaintiff over the suit
property.
3. The 3rd Defendant is a contractor/Masteri who is said to be carrying
on unauthorized construction activities in the suit property at the
instance of the 1st Defendant.
4. I submit that, on 07.01.2025, this Hon’ble Court was pleased to direct
issuance of private notice to the 3rd Defendant, returnable by
25.02.2025.
5. I submit that in pursuance of the said order, the then counsel for the
Plaintiff issued notice to the 3rd Defendant via Registered Post on
30.12.2024 to his last known address at:
Plot No.648, VI Main Road, Ram Nagar South, Madipakkam,
Chennai.
6. The said notice was returned undelivered with the endorsement dated
01.01.2025 stating "No such person" at the address. The returned
postal cover clearly indicates that the 3rd Defendant is evading service
and cannot be served by ordinary means. It is respectfully submitted
that despite best efforts, ordinary service of summons has failed.
7. I state that this Hon’ble Court has now posted the matter on
26.03.2025 for steps for substituted service.
8. In view of the above, it is just and necessary that substituted service be
permitted by way of:
a. Affixture of summons on the outer door of the 3rd Defendant’s
last known address; and
b. Publication in a English and Tamil daily newspaper having
circulation in the locality of Madipakkam, Chennai.
Solemnly affirmed at Sholinganallur } BEFORE ME,
On this 26 day of March, 2025 and}
th
signed his name in my presence } ADVOCATE, SHOLINGANALLUR
BEFORE THE HON'BLE DISTRICT
MUNSIF COURT CUM JUDICIAL
MAGISTRATE, SHOLINGANALLUR
I.A. No. OF 2025
In
O.S No. 416/2024
K. RANI,,
Rep. by Power Agent Mr. Manish
Kumar
…Petitioner/Plaintiff
-Versus-
1. V.RANI
W/o Valayapathy
2. M.VEERASAMY
3. MR. VELAYUTHAM
… Respondents
AFFIDAVIT OF PETITIONER
K.M.MRITHUNJAYAN
COUNSELS FOR PLAINTIFF
BEFORE THE HON’BLE DISTRICT MUNSIFF COURT AT
SHOLINGANALLUR
I.A No. of 2025
in
O.S. No.416 of 2024
K. RANI,
W/o D. Kumar,
Rep. by Power Agent Mr. Manish Kumar,
E-20/56, Siddarth Nagar, New Delhi – 110014. …Petitioner/Plaintiff
-Versus-
1. V.RANI
W/o Valayapathy
Plot No.648,
4TH main road, Ram Nagar South,
Madipakkam, Chennai
Also having address at
No.11, Malayappan Street,
Mandavelipakkam,
Chennai- 600 028
2. M.VEERASAMY
Plot No.648,
4TH main road,
Ram Nagar South,
Madipakkam, Chennai.
3. MR. VELAYUTHAM
Plot No.648,
4TH main road,
Ram Nagar South,
Madipakkam, Chennai. … Respondents/ Defendants
PETITION FILED UNDER ORDER V RULE 20 OF CPC
For the reasons stated in the accompanying affidavit, it is most humbly
prayed that this Hon’ble Court may be pleased to order substituted service of
summons on the 3rd Defendant in O.S. No.416/2024 by affixing a copy of the
summons on the outer door or some conspicuous part of his last known
residence and by publication in a English and Tamil Daily newspaper having
wide circulation in Chennai and/or Madipakkam area, and pass such further
or other orders as this Hon’ble Court may deem fit and proper and thus render
justice.
Dated at Sholinganallur on this the 26th day of March, 2025.
COUNSEL FOR PETITIONER/PLAINTIFF
BEFORE THE HON'BLE DISTRICT
MUNSIF COURT CUM JUDICIAL
MAGISTRATE, SHOLINGANALLUR
I.A. No. OF 2025
In
O.S No. 416/2024
K. RANI,,
Rep. by Power Agent Mr. Manish
Kumar
…Petitioner/Plaintiff
-Versus-
V.RANI
W/o Valayapathy
M.VEERASAMY
MR. VELAYUTHAM
… Respondents
PETITION FILED UNDER ORDER V
RULE 20 OF CPC
K.M.MRITHUNJAYAN
COUNSELS FOR PLAINTIFF
